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USWAG Update: SPCC & CCP Issues. Jim Roewer APPA E&O Conference April 18, 2007. Spill Prevention Control & Countermeasures (SPCC) Regulations. SPCC Rule Revisions Timeline. SPCC Rule (40 CFR 112 ) Promulgated 1973 Revisions Proposed 1991; Additional Amendments Proposed 1993 & 1997) - PowerPoint PPT Presentation
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USWAG Update:SPCC & CCP Issues
Jim Roewer
APPA E&O Conference
April 18, 2007
Spill Prevention Control & Countermeasures(SPCC) Regulations
SPCC Rule Revisions Timeline
SPCC Rule (40 CFR 112 ) Promulgated 1973 Revisions Proposed 1991; Additional
Amendments Proposed 1993 & 1997) SPCC Amendments Published July 17, 2002,
Effective August 16, 2002; Deadline = August 2003
2003 Deadline Extension to August 2006
Oil-filled Equipment & Small Facility SPCC Rule
ANPR September 2004 Proposed Rules December 2005 Extension of Compliance Deadlines to
October 31, 2007 (or 1 year from Final Rule) Tailored SPCC Program for Electrical
Equipment & Small Facilities Final Rule Published December 26, 2006
Oil-filled Equipment & Small Facility SPCC Rule
Reduces Regulatory Burdens Oil-filled Equipment Small Facilities (“Qualified Facilities”) Mobile Refuelers Motive Power
Oil-filled Equipment
Oil-filled equipment is subject to rule Equipment volume included in threshold
determination Equipment excluded from “bulk storage
container” definition, avoids requirements for: bulk storage secondary containment corrosion protection periodic integrity testing inspection
Qualified Oil-filled Equipment
Oil-filled Electrical Equipment with Clean Discharge History for Past 3 years ✔ Discharges from Electrical Substations ~20/Year
Industry-wide Subject to Monitoring & Inspection Contingency Plan in lieu of General
Secondary Containment
Qualified Facilities
≤ 10,000 gallons Aggregated Oil Capacity Clean Discharge History for Past 3 Years Self-certification of SPCC Plan Streamlined Integrity Testing Requirements Streamlined Facility Security Requirements
Mobile Refuelers
Mobile Refueler = Bulk Storage Container onboard a Vehicle
Sized Secondary Containment No Longer Required
General Secondary Containment Still Required
Refueling vs. Oil Transfer
Motive Power
On-board Fuel Tank Motive Power Containers Exempt from SPCC
Rule
SPCC Summary
Relief for Small Facilities (<10,000 gal) Relief from Secondary Containment for
Electrical Equipment Mobile Refuelers Motive Power Exemption
SPCC Summary
Relief for Small Facilities (<10,000 gal) Relief from Secondary Containment for
Electrical Equipment Mobile Refuelers Motive Power Exemption Compliance Deadline Proposed Extension to
July 1, 2009
USWAG SPCC Workshops
June 6, 2007
PSEG
Newark, NJ
October 3, 2007
PGE
San Francisco
Coal Combustion Product (CCP)
Management Issues
CCP Regulatory Background
August 1993 & May 2000 Non-Hazardous Regulatory Determinations
Rulemaking Schedule: CCP Disposal
NODA April 2007
Mineplacement OSM ANPRM March 2007
EPA NODA
Updating Record Since 2000 Regulatory Determination EPA – DOE Report on New Facilities Revised Risk Modeling USWAG CCP Action Plan Environmental Groups’ Proposed Subtitle D
Regulations
EPA/DOE New CCP Disposal Facility Report
Survey of New (post-1994) CCP Disposal Facilities ~60 facilities identified
Analysis of Permit Requirements Liners, Groundwater Monitoring required for
Nearly All Review of State Regulations
Increasing Stringency
UTILITY INDUSTRY ACTION PLAN FOR THE
MANAGEMENT OF COAL COMBUSTION PRODUCTS
Submitted to the
United States Environmental Protection AgencyOffice of Solid Waste
Ariel Rios Building1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
by the
Utility Solid Waste Activities Group701 Pennsylvania Avenue, NWWashington, D.C. 20004-2696
202-508-5645
October 2006
USWAG CCP Action Plan
Voluntary Program Designed to: Adopt Groundwater Performance Standards at
Landfills, Surface Impoundments Implement Comprehensive Monitoring Program to
Measure Compliance with Performance Standards
Ensure no CCPs Placed in Sand & Gravel Pits without Appropriate Engineering Controls
Consider Dry Handling for New CCP Management Units
USWAG CCP Action Plan
Implementation of the Action Plan will Achieve Enhanced Environmental Protection on a More Rapid Timetable than Through EPA’s Regulatory Process
Will Fill any Perceived Gaps in State Regulations
OSM ANPRM - March 14, 2007
Implementation of NAS Report on Mineplacement SMCRA Does Not Contain Explicit Regulations
Addressing CCP Mineplacement Modifications to SMCRA Title V, Title IV Likely OSM Commitment to Mine Reclamation &
Environmental Protection Anticipated Schedule: Proposed Rule - 2007,
Final Rule - 2008
CCP Disposal and Mineplacement
No Need for Comprehensive Federal Regulatory Program Performance Based Standards for Disposal and
Mineplacement State Regulatory Oversight for Disposal and
Mineplacement EPA’s Role = Technical Assistance & Filling Gaps
CCP Management Challenges(Impact of Mercury Rules)
Cross Media Impacts Questions re. Increased Hg Levels in CCPs Implications for Disposal Implications for Utilization
Cement & Concrete Cement Manufacture Gypsum Sheet Product Manufacture Agricultural Applications
CCP Management Challenges(Impact of Mercury Rules)
Portland Cement Kiln NESHAP December 20, 2006 Final Rule Hg Control for Existing Kilns Rejected Ban on Use of Fly Ash as Kiln
Feedstock Ban on Fly Ash with Increased Hg from Sorbent
Injection Reconsideration of Rule (Limits, Fly Ash Ban) PCA, Earthjustice Lawsuits
CCP Issues Summary
Regulatory Future Uncertain Non-hazardous Status of CCPs Critical Disposal & Mineplacement Regulations
CAA Implementation Will Affect CCPs Regulatory Status Unlikely to be Affected Impact on Utilization Possible